Anti-Money Laundering & Counter Financing of Terrorism (AMLA/CFT) Policy

1. Introduction & Commitment

WMY OFFICIAL EMPIRE (SSM: 003598675-U), operating Mango Live Diamond Topup at amdagency.net, is committed to preventing money laundering and the financing of terrorism. This policy outlines our approach to compliance with applicable Malaysian laws and regulations.

This policy is designed in accordance with:

• Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA)
• Malaysian Anti-Corruption Commission Act 2009
• Bank Negara Malaysia (BNM) guidelines on AML/CFT

2. Definitions

• Money Laundering: The process of making illegally-obtained money appear legitimate.
• Terrorism Financing: Providing funds or financial services to support terrorist activities.
• Suspicious Transaction: Any transaction that appears unusual or has no apparent lawful purpose.
• STR: Suspicious Transaction Report filed with relevant authorities.
• KYC: Know Your Customer - the process of verifying customer identity.

3. Risk Assessment

We conduct regular risk assessments to identify and mitigate money laundering and terrorism financing risks associated with our business operations. Risk factors considered include:

• Product Risk: Digital goods (Mango Live diamonds) that could be used for value transfer.
• Customer Risk: Anonymous or guest purchases with minimal identification required.
• Transaction Risk: High-value, frequent, or unusual transaction patterns.
• Geographic Risk: Transactions originating from high-risk jurisdictions.

4. Know Your Customer (KYC) Procedures

Our KYC procedures include:

4.1 Guest Customers

• Collection of Mango Live ID and WhatsApp number for each transaction.
• Monitoring of transaction patterns linked to the same ID or WhatsApp number.
• Enhanced verification may be triggered for high-value or frequent transactions.

4.2 Registered Resellers

• Registration with email address, name, and contact details.
• Manual approval process by administrators.
• Ongoing monitoring of transaction volume and patterns.
• Enhanced due diligence for high-volume resellers.

5. Transaction Monitoring

We monitor transactions for suspicious activities including:

• Unusually large or frequent purchases.
• Multiple transactions just below reporting thresholds.
• Purchases using multiple payment methods by the same individual.
• Rapid successive transactions to different Mango Live IDs.
• Transactions that appear to serve no legitimate purpose.
• Patterns indicating potential structuring or layering of funds.

6. Suspicious Activity Reporting

When suspicious activity is detected:

1. The transaction is flagged for internal review.
2. The Compliance Officer conducts an investigation.
3. If warranted, a Suspicious Transaction Report (STR) will be filed with the relevant authorities.
4. The customer's account or further transactions may be suspended pending investigation.

We are prohibited from informing customers that a STR has been or is being filed about them (tipping off prohibition).

7. Record Keeping

We maintain comprehensive records including:

• All customer identification information collected.
• Transaction records including amounts, dates, and recipient details.
• Internal investigation reports and findings.
• Correspondence related to suspicious activity investigations.

Records are retained for a minimum of 7 years from the date of the transaction or the end of the business relationship, whichever is later.

8. Transaction Limits

To mitigate risk, we implement the following measures:

• Maximum transaction limits per order.
• Daily transaction limits per customer (based on Mango Live ID or WhatsApp number).
• Enhanced due diligence for transactions exceeding certain thresholds.
• Right to refuse or delay transactions that raise concerns.

9. Staff Training

All personnel involved in operations are trained on:

• Recognising suspicious activities and red flag indicators.
• Internal reporting procedures for suspicious transactions.
• KYC requirements and customer verification procedures.
• Legal obligations under Malaysian AML/CFT regulations.
• Consequences of non-compliance.

10. Sanctions Screening

We screen against relevant sanctions lists to ensure that our services are not being used by sanctioned individuals or entities. Transactions involving sanctioned parties will be blocked and reported to the relevant authorities.

11. Compliance Officer

Our designated Compliance Officer is responsible for:

• Overseeing implementation of this policy.
• Reviewing and approving suspicious transaction reports.
• Ensuring staff training is conducted regularly.
• Liaison with regulatory authorities as required.
• Regular policy reviews and updates.

12. Customer Cooperation

By using our services, customers agree to:

• Provide accurate and truthful information.
• Cooperate with identity verification requests when required.
• Not use our services for money laundering, terrorism financing, or any illegal purpose.
• Promptly respond to any compliance inquiries.

13. Policy Review

This policy is reviewed annually and updated as necessary to reflect:

• Changes in applicable laws and regulations.
• Updates to our risk assessments.
• Industry best practices and evolving threat landscape.
• Findings from internal or external audits.

14. Contact Information